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CITYWIRE PRIVACY POLICY

Citywire Financial Publishers Limited (‘Citywire’, ‘we’, ‘us’, ‘our’) is the
operator and copyright holder of certain websites (‘the websites’) including but
not limited to citywire.com. 

Citywire is an independent publisher of financial information and a data
provider.



HOW AND WHEN WE COLLECT YOUR PERSONAL INFORMATION

This privacy policy (‘Privacy Policy’) tells you what personal information we
collect about you, how we collect it, and what we will do with it. We may
collect personal information when you:

 * Visit our websites
 * Order services from our websites
 * Create an account to use our websites
 * Update your profile and other account details
 * Subscribe to or receive our newsletter, magazines, and other marketing
   messages
 * ‘Follow’, ‘like’, post to, or interact with our social media accounts,
   including Facebook, LinkedIn, Twitter, and YouTube
 * Submit correspondence to us, make an enquiry, provide feedback or make a
   complaint by post, over the phone, by email or on our website
 * Register for and/or attend our virtual and physical events
 * Are a fund manager who we rate for Citywire Fund Manager Ratings
 * Complete questionnaires or surveys
 * Register for a magazine, subscribe to our newsletter and mailing lists
 * Submit a CV and/or an application to a job vacancy
 * Have a face-to-face meeting with us
 * Otherwise interact with us

This Privacy Policy also explains what rights you have to access or change your
personal information.

Our websites are not intended for children. We do not knowingly collect or
maintain the personal information of children under the age of 18. If you are
under the age of 18, please do not access our websites at any time or in any
manner. We will take appropriate steps to delete the personal information of
persons under the age of 18.



ABOUT US

We are Citywire Financial Publishers Limited, a company registered in England
under company number 03828440, with our registered address as set out below.

You can contact us as follows:

FAO: Data Protection Officer
Address: Citywire Financial Publishers Limited, 3 Spring Mews, London, SE11 5AN,
United Kingdom
Email: privacy@citywire.co.uk



VISITORS TO OUR WEBSITES

Personalisation, website usage and third-party analytics

We may collect certain information about how you use and access our websites
even where you have not created a Citywire account or logged in. This might
include:

 * Information about your device, operating system, and IP address
 * Your login information
 * Your browser type and version
 * Information about your visit, including URL, clickstream (i.e.: your journey
   to, through and from our site), length of visits to certain pages, and page
   interaction information

We collect this information by, for example, using cookies and other similar
technologies, and we sometimes use third-party services such as Google Analytics
to analyse website user activity on our behalf. You can see what cookies we are
using for personalisation at any time by reading our cookie policy. 

 

Your Citywire account and profile

To read some of our content and use our services we may ask you to create a
Citywire account (your profile). To do this we ask you provide us with your
email address (in the case of our professional websites this should be your work
email address), a password, your name, job title/position, company you work for
(if applicable), and other information prompted on the registration page. We ask
that you provide accurate information: we may use publicly available information
on the internet to verify that your email address is valid, along with other
information you provide at the time of registration. This information is stored
in our secure databases and is used to create, maintain, and/or add to your user
profile.

When you create an account, we may classify you within our database based on
your profession and the type of company you work for (if applicable). We may add
this to your profile, along with an estimate of your assets under management
(AUM) (if applicable), a record of the content on our websites you read or
engage with, answers to polls you may answer on our websites, answers to surveys
undertaken at our events (if applicable) and a record of articles and content on
our websites in which you may be featured (if applicable).

We may also create a profile of you based on publicly available information. We
may then use this information to infer certain information about your interests
and relevant content and share this with our partners/clients to deliver more
relevant content to you and for their own internal purposes.

 

How we use your profile

When you visit our websites we use a cookie to assign you a randomly generated
unique identifier. We log your activity on our websites against this identifier
in our databases. Once in our databases, this information will be added to your
user profile and we use this data to provide you with access to our websites in
a manner convenient and optimal to you, deliver you content and advertisements
that are relevant to you and improve your user experience.

 

Sharing your profile

We only share your personal information (and your profile) with service
providers and other third parties we work with to deliver our services to you.
We do not share your personal information with third parties for the purpose of
such third party’s advertising activities unless you have given us your consent
to do so. We may share, however, an aggregated and anonymised version of this
information with companies that advertise, or may advertise, on our websites.
Allowing companies to advertise on our websites helps us offer certain content
for free. Additionally, we may use an aggregated and anonymised version of this
information in reports, presentations and other products for internal and
external uses.

 


THIRD-PARTY MARKETING CONTENT

If you are (a) a professional reader of Citywire or (b) a consumer reader who
has opted in to receive third-party marketing about our selected partners, we
may send marketing emails to you on behalf of asset managers and other financial
institutions containing their relevant marketing and advertising messages. We
never pass your details to them directly, but may use trusted third-party data
processing companies to send such marketing emails on our behalf or to manage
our email suppression lists. We ensure that they handle your data securely and
delete it from their systems when no longer needed for the purpose we have
shared it with them. For more information on our third-party data processing
companies, please see section titled ‘Sharing and disclosing your information’
below or email privacy@citywire.co.uk.

You may unsubscribe from emails relating to our selected partners at any time in
the ‘My Account’ section of the websites, by using the embedded links set out in
the emails or by replying to the relevant emails you receive from us. 

 


CITYWIRE EMAILS AND MARKETING

We will send you our daily newsletters and emails about our news, events, new
website features or services that we believe may interest you if you are (a) a
professional account holder or (b) a consumer account holder and you have either
opted-in to receive our daily newsletters and such other Citywire marketing
messages or we are otherwise allowed to send you such messages.

You can opt out of receiving such messages at any time in the ‘My Account’
section of the websites, by using the embedded links set out in our emails or by
replying to the relevant emails you receive from us. You can also use the ‘My
Account’ section to choose to subscribe to any of our other more specific news
emails that you want to receive.

If you are a professional reader of our websites, we may use the information you
have provided us with, along with the information we have collected from your
website activities, to subscribe you to email newsletters that we feel would be
relevant to you. You can opt out of these in the same way as all other
newsletters. If, as a consumer reader of our websites, you opt in to receive
direct marketing from us or we are otherwise allowed to send you such messages,
we will send you carefully selected emails marketing our events and other
products. These will never be excessive or irrelevant to you and you can opt out
of receiving them at any time via the ‘My Account’ section of the website, by
using the embedded links set out in our emails, by replying to the relevant
emails you receive from us, or by emailing privacy@citywire.co.uk.

As part of our marketing efforts, we may also match personal information that
you provide to us directly with other information about you obtained from or
held by third-party sources (such as social media platforms). We may use this
personal information to inform our marketing strategy and to tailor and show
advertisements more relevant to you.

 


SOCIAL MEDIA INTERACTIONS

We will use your personal information to interact with you on social media
platforms including Facebook, LinkedIn, Twitter, and YouTube, for example, to
respond to comments and messages, post, ‘retweet’ and ‘like’ posts. When you
interact with us on social media platforms, we may collect information you share
with us on such platforms and also keep records of our interactions.

 


USER AND CUSTOMER SUPPORT

We will use your personal information to provide customer service and support,
deal with enquiries or complaints about our websites and services, and to manage
our relationship with you, which will include notifying you about changes to our
website terms and conditions or this Privacy Policy. We may also share your
information with our third-party service providers as necessary to provide such
customer support.

If you contact us with a complaint or query, we may keep a record of any phone
number/email address used to call/email our customer service team as well as the
correspondence and the period of time it took for us to deal with a query or any
request you had. We may also record your levels of satisfaction with the
services we have provided. We will also collect any information contained in any
other correspondence between us.

 


EVENTS REGISTRATION AND PARTICIPATION

This section is applicable to both virtual and physical events, unless we
explicitly refer to one of them.

If you sign up to attend one of our events we will ask you to provide your
personal and professional details, such as your name, surname, title, job
title/position, company you work for (if applicable) as well as your contact
details. This is so we can assess your suitability to attend our event, contact
you to let you know if you meet our criteria, and share with you all logistical
information.

If you register for one of our events we will use this information internally
for liaising with you and ensuring that you are added to appropriate workshops
and seminars at the event.

If you are coming to one of our physical events we may ask you for further
information such as your dietary requirements, passport details and any special
needs or requirements in accordance with the Equality Act 2010. This information
(in particular so-called ‘special categories’ of particularly sensitive personal
information such as, for example, information about your race or ethnicity, or
your health and genetic data) will be treated with the utmost respect and will
only be used for logistical purposes to make sure you have a comfortable and
enjoyable experience at our event. We have in place appropriate safeguards which
we are required by law to maintain when processing such data. We process special
categories of personal information only with your explicit consent, where it is
needed for reasons of substantial public interest for equal opportunities
monitoring, or where we need it to carry out our legal obligations.


Sharing your event information

Where we are legally permitted to do so, we may pass some of the information we
collect at registration to our event sponsors so that they know who will be
attending the event. We will always let you know in advance about the identity
of such event sponsors. They may contact you after the event for feedback via
call or email and send you marketing via email. We are not responsible for their
privacy practices and their interactions with you – it is up to you whether you
remain in contact with them.

We may share your job title and company name with potential sponsors so they
know the calibre of people that attend our events.

 

Surveys at events

At the events we may ask you to complete surveys. At physical events we conduct
surveys via electronic tablets or on paper. These may be used to gain feedback
on our events or allow us to find out more about the type of funds or assets you
have under management (if relevant). Some may give you a chance to tell us about
your organisation and if you think there is anyone else there that would like to
attend one of our future events. This information is added to your user profile
and aids us in continuing to offer you relevant content and to invite you to
future events.

We also sometimes run surveys at our events on behalf of the event sponsors. If
this is the case, we will check that you are happy to share your answers and
other personal data with the relevant sponsor. For more information about how we
use and share survey data, please see the section titled ‘Questionnaires and
Surveys’ below.

 

Recording at our events

There will be a photographer and/or videographer at our events. If you are
filmed, photographed, and/or recorded as part of any of our events, your image
or likeness may be used for future event show guides, in promotional material,
sponsor and media partner coverage in print, online or social media channels.

 


QUESTIONNAIRES AND SURVEYS

At Citywire we value your opinion and we often run surveys and questionnaires in
person, via email or telephone. These are primarily conducted for our own
purposes such as to allow us to study how our websites and services are used and
to stay engaged with our audience, but are also sometimes conducted by us on
behalf of third parties. When they are carried out on behalf of third parties we
will always state that this is the case at the beginning of the survey, inform
you about the identity of the third party and give you the right to object to
our sharing of your personal data (such as name and email address) with such
third parties. In certain circumstances we may also share anonymised and
aggregated survey data with such third parties to protect your privacy.

When we conduct the surveys for our own purposes, the answers you give may be
aggregated and anonymised and used for both internal and external presentations
and news stories. Survey information will also be stored in our database and
added to your user profile.

 


MAGAZINE REGISTRATION

In order to send you a hard copy of one of our magazines we ask you to provide
us with your contact details such as your name and postal address. This is
shared with our printers, courier services, and other service providers for
logistical purposes but we never share it with any other companies for marketing
purposes. The address will be added to your user profile in our database and may
be used for geographical profiling.

As with our other communications, you can always opt out of receiving our
magazines and other materials via post. You can do so by sending an email to us
at privacy@citywire.co.uk.

 


FACE-TO-FACE MEETINGS

At Citywire we like to engage with our audience and we will sometimes request
the chance to meet you and ask you questions. We will usually record and then
transcribe any meeting that we have with you. Any opinions that you express will
be stored in our database and will be linked to your user profile.

Please also note that if you visit our offices, your image and voice may be
captured by our CCTV cameras which we use for security purposes.

 


CITYWIRE FUND MANAGER RATINGS

Citywire operates a ratings system based on the performance of fund managers. As
part of this, if you are an active fund manager, you may be contacted by
Citywire staff for your photograph, a short biography, date of birth, career
history and any other relevant information. They will ask you if you are happy
for us to use and publish this information as part of your manager profile. If
you agree, then this information will be added to our database and published
online. We will regularly check in with you that this information is up to date
and that you are happy with our continued publication of it.

 


RECRUITMENT

If you submit a CV or job application to Citywire, whether directly or via an
agent or recruiter, you may share with us additional information about your
academic and work history, qualifications, skills, projects and research that
you are involved in, references, proof of your entitlement to work, your
national security number, your passport or other identity document details, and
any other such similar information. We will collect and use this information to
process your job application and we may contact your recruiter, current and
former employers and/or referees to obtain further information about you and
your application.

 


COMPLIANCE WITH POLICIES, PROCEDURES, AND LAWS

We may collect and use your personal information to protect, investigate, and
deter against fraudulent, unauthorised, or illegal activity, including identity
fraud as well as to enable us to comply with our policies and procedures and
enforce our legal rights, or to protect the rights, property or safety of our
employees. 

 


LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION

We will only use and otherwise process your personal information where we have a
legal basis to do so. The legal basis will depend on the purposes for which we
collect and use your personal information. In almost every case the legal basis
will be one of the following:

Consent: for example, where you have provided your consent to receive certain
marketing from us. You can withdraw your consent at any time, including by
clicking on the ‘unsubscribe’ link at the bottom of any marketing email we send
you;

Our legitimate business interests: where it is necessary for us to understand
our readers, promote our services, and operate a safe and lawful business,
provided in each case that this is done in a legitimate way which does not
unduly affect your privacy and other rights. For example, we will rely on this
legal basis when we conduct certain market analysis to understand our readers in
sufficient detail so we can improve our services;

Performance of a contract with you (or in order to take steps prior to entering
into a contract with you): for example, where you have asked us to provide one
of our services to you and we need to use your contact details and financial
information in order to deliver this service; or

Compliance with law: where we are subject to a legal obligation and need to use
your personal information in order to comply with that obligation.

 


SHARING AND DISCLOSING YOUR INFORMATION

In connection with the purposes described above, we will share your personal
information when relevant with third parties such as:

 * Our suppliers, business partners and service providers we work with to
   deliver our services to you and to market and advertise our services
 * For the purposes of research, evaluation, and analysis
 * Any selected third parties and sponsors that you consent to our sharing your
   information with
 * Our corporate affiliates and other members of our group of companies
 * Regulators and governmental bodies and other authorities who require
   reporting of processing activities in certain circumstances
 * Prospective sellers and buyers of our business or assets, only if we decide
   to sell or buy any business or assets
 * Other third parties, including but not limited to legal or other advisers,
   regulatory authorities, licensing bodies, courts, law enforcement agencies
   and government agencies (this includes exchanging information with other
   companies and organisations for the purposes of fraud protection and credit
   risk reduction), where necessary to enable us to enforce our legal rights, or
   to protect the rights, property or safety of our employees or where such
   disclosure may be permitted or required by law

 


DATA TRANSFERS

Citywire is a global business with offices in London, Munich, Singapore, Milan
and New York. We have UK and EU approved Model Contract Clauses in place between
all of our entities so you have adequate protection if your data is transferred
to a country which has not been assessed by the UK and/or European Commission as
having adequate legal protection.

As many of our external third parties are based outside the UK and/or European
Economic Area (EEA), their processing of your personal information will involve
a transfer of data outside the UK and/or EEA, including to countries which have
less strict, or no data protection laws, when compared to those in the UK and/or
European Union.

Whenever we transfer your information as described in the paragraph above, we
will take steps which are reasonably necessary to ensure that adequate
safeguards are in place to protect your personal information and to make sure it
is treated securely and in accordance with this Privacy Policy. In these cases,
we rely on approved data transfer mechanisms (such as the EU or UK ‘Standard
Contractual Clauses’) to ensure your information is subject to adequate
safeguards in the recipient country. Please contact us using the contact details
at the top of this Privacy Policy if you want further information on the
specific mechanism used by us when transferring your personal data out of the UK
and/or EEA.

 


OUR SECURITY AND RETENTION OF YOUR INFORMATION

We want our users and members to feel confident using our services and are
committed to protecting the information that we collect by using appropriate
technological and operational security measures. For example, information
transmitted to us over the internet is secured using secure socket layer (SSL)
technology and industry-standard firewalls. We also ensure information once
received is stored securely and only accessible with the correct authorisation. 

You must keep your password and any other authentication information for our
website confidential. If you know or suspect that anyone other than you knows
your password or any other authentication information, you must promptly notify
us using the contact details below.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your information transmitted
during your use of our website.

We retain your information only for as long as is necessary to provide you with
the services that you have requested from us, for as long as we reasonably
require to retain the information for our lawful business purposes, or where we
are legally permitted to do so. We operate a data retention policy and look to
find ways to reduce the amount of information we hold about you and the length
of time that we need to keep it.



DATA PROTECTION OFFICER

Citywire’s data protection officer’s details and credentials are below:

Data Protection Officer
Citywire Financial Publishers Limited
3 Spring Mews

London

SE11 5AN
United Kingdom
+44 207 840 2461
privacy@citywire.co.uk

 


YOUR RIGHTS TO YOUR PERSONAL DATA

You have certain rights in respect of the information that we hold about you,
including:

 * The right to be informed of the ways in which we use your information, as we
   seek to do in this Privacy Policy
 * The right to ask us not to process your personal data for marketing purposes
 * The right to request access to the information that we hold about you
 * The right to request that we correct or rectify any information that we hold
   about you which is out of date or incorrect
 * The right to withdraw your consent for our use of your information in
   reliance of your consent, which you can do by contacting us using any of the
   details at the top of this Privacy Policy
 * The right to object to our using your information on the basis of our
   legitimate interests or those of a third party, and there is something about
   your particular situation which makes you want to object to processing on
   this ground
 * The right to receive a copy of any information we hold about you (or request
   that we transfer this to another service provider) in a structured, commonly
   used, machine-readable format, in certain circumstances
 * In certain circumstances, the right to ask us to limit or cease processing or
   erase information we hold about you
 * The right to lodge a complaint about us to the UK Information Commissioner’s
   Office (https://ico.org.uk/) as well as a right to lodge a complaint with the
   relevant authority in your country of work or residence. If you have any
   concerns about the way we have processed your personal information, we
   request that you initially contact us (using the contact details above) so
   that we can investigate, and hopefully resolve, your concerns

Please note that we may need to retain certain information for our own
record-keeping and research purposes. We may also need to send you
service-related communications relating to your website user account even when
you have requested not to receive marketing communications.


How to exercise your rights

If you wish to exercise your ‘Right to Access’, ‘Right to be Forgotten’, or any
other right under the UK and/or EU General Data Protection Regulation, then
please get in touch with us at privacy@citywire.co.uk or call +44 207 840 2250.
You can also write to us –

Data Protection Officer
Citywire Financial Publishers Limited
3 Spring Mews
Vauxhall
SE11 5AN
United Kingdom

We will comply with your requests unless we have a lawful reason not to do so.

 

What we need from you to process your requests

We may need to request specific information from you to help us confirm your
identity and to enable you to access your personal information (or to exercise
any of your other rights). This is a security measure to ensure that personal
information is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your
request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances. We will try to respond to all
legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

 


THIRD-PARTY LINKS AND WEBSITES

Our websites may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.

 


CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may make changes to this Privacy Policy from time to time. We will post any
changes to our site or notify you of any material changes by email or by a
notification on our website.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us by updating your profile account information or contacting
us via the contact details at the top of this Privacy Policy.


This Privacy Policy was last reviewed and updated in January 2023.

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